Queen Mary, University of London

Dr Christiana HJI Panayi BA BCL PhD
Lecturer in Tax Law

Christiana is a lecturer in Tax Law at Queen Mary, University of London. She teaches on the EC Tax Law, International Tax Law and UK Business Taxation courses of the LLM Programme.

Christiana is also a researcher at the Institute for Fiscal Studies. She is preparing a report on the Common Consolidated Corporate Tax Base for the Tax Law Review Committee.

Christiana studied at Oxford University for the BA in Jurisprudence and for the BCL. She also has a PhD from the London School of Economics. Her doctoral thesis entitled “Double Taxation, Tax Treaties, Treaty Shopping and the European Community” has won the 2007 tax thesis competition conducted jointly by the European Commission and the European Association of Tax Professors. The thesis was also published by Kluwer Law, EUCOTAX Series in 2007.

Christiana is a solicitor of England & Wales and an advocate of the Cyprus Supreme Court. Before joining Queen Mary, she had worked for Allen & Overy. Christiana is also a member of the Law Society and the Cyprus Bar Association.

Christiana has published extensively in the area of EC and International Tax Law. She speaks regularly at tax conferences and teaches abroad. Last year, Christiana lectured at NYU, at the Academy of European Law, at the University of Cyprus and at the Malta Institute of Management.

Research Interests

Christiana’s research interests are in the area of European Community tax law, international tax law and taxation of corporate finance.  She also has a keen interest in US and Cypriot tax law, international treaty law, state aid law and the external affairs of the European Community.

Christiana’s current research focus in on the human rights implications of various international and European tax developments.

Publications:

Books

  1. Double Taxation, Tax Treaties, Treaty Shopping and the European Community, Kluwer Law International, EUCOTAX Series 2007; ISBN/ISSN 9041126589
  2. “The Common Consolidated Corporate Tax Base and the UK”, report for the Tax Law Review Committee of the Institute for Fiscal Studies (sole author) – forthcoming

 Chapters in Books

  1. “European Tax Law: Legislation and Political Initiatives, in Gore-Browne on EU Company Law (Jordan Publishing); ISBN: 0853084009 (Updated three times a year)
  2. “European Community Tax Law and Companies: Principles of the European Court of Justice”, in Gore-Browne on EU Company Law (Jordan Publishing); ISBN: 0853084009 (Updated three times a year)
  3. “Inbound investment and thin capitalization”, in The Common Consolidated Corporate Tax Base (Linde); ISBN: 978-3-7073-1306-2
  4. “UK Corporate Residence”, in Residence of Companies under Tax Treaties and EC Law (EC and International Tax Law Series, volume 5, IBFD Publications, 2009)

Articles

  1. “Open Skies for European Tax?”, [2003] British Tax Review 189-202 (Sweet & Maxwell); ISSN: 0007-1870
  2. “Limitation on Benefits and State Aid”, 44 [2004] European Taxation 83-98 (IBFD Publications); ISSN: 0014-3138
  3. “State aid and Tax: The Third Way?”, 32 [2004] Intertax 287-311 (Kluwer Law International); ISSN: 0165-2826
  4. (Publication Review) The Impact of Community Law on Tax Treaties: Issues and Solutions, [2004] British Tax Review 582-583; ISSN: 0007-1870
  5. “Ships and Taxes: Does the Case of Commission v. Netherlands have Tax Implications?”, 45 [2005] European Taxation 97-102; ISSN: 0014-3138
  6. “Family Office: Wealth Management in the 21st Century”, Trusts and Estates Law & Tax Journal, May 2005; ISSN: 1743-5501
  7. “Agency Permanent Establishments in Securitisation Transactions”, 33 [2005] Intertax 286-296; ISSN: 0165-2826
  8. “The Schempp case: A new leaf in the jurisprudence of the Court of Justice or just a fig leaf?”, 45 [2005] European Taxation 482-487; ISSN: 0014-3138
  9. “Treaty-shopping and other tax arbitrage opportunities in the European Union: A Reassessment – Part 1”,46 [2006] European Taxation 104-111; ISSN: 0014-3138
  10. “Treaty-shopping and other tax arbitrage opportunities in the European Union: A Reassessment – Part 2”,46 [2006] European Taxation 139-155; ISSN: 0014-3138
  11. “Exploring the Open Skies: EC-incompatible treaties between Member States and Third Countries”, [2006] Yearbook of European Law 315; ISBN: 0263-3264
  12. “Multistate Cumulative Tax Burdens and Reliefs in the European Community - Lessons from the United States”, 47 [2007] European Taxation 15; ISSN: 0014-3138
  13. “The Protection of Third-Country Rights in Recent EC Case Law”, Tax Notes International, 19 February 2007; ISSN: 1058-3971
  14. “The Effect of Community Law on Pre-Accession Tax Treaties”, 16/3 [2007] EC Tax Review 120; ISSN: 0928-2750
  15. “Thin Capitalisation GLO et al. – a thinly concealed agenda?”, 35 [2007] Intertax 298; ISSN: 0165-2826
  16. “Tax Treaty Law and Community Law – Some Recent Developments”, [2007] 3 EC Tax Journal 10; ISSN: 1350-1089
  17. “Recent Developments to the OECD Model Tax Treaty and EC Law”, 47 [2007] European Taxation 452; ISSN: 0014-3138
  18. “The Common Consolidated Corporate Tax Base: Issues for Third Countries and Member States opting out”, 48 [2008] European Taxation 114; ISSN: 0014-3138
  19. “The Fundamental Freedoms and Third Countries”, 48 [2008] European Taxation 571; ISSN: 0014-3138
  20. (Publication Review) Free Movement of Capital, Income Taxation and Third Countries: Four Selected Issues, [2008] British Tax Review 413; ISSN: 0007-1870
  21. “The proposed amendments to the Savings Directive”, 49 [2009] European Taxation 179
  22. “Corporate Mobility under Private International Law and European Community Law: Debunking Some Myths”, [2009] Yearbook of European Law (forthcoming)
  23. “Corporate mobility in the European Union and Exit Taxes”, [2009] Bulletin for International Fiscal Documentation 459
  24. “Tax Treaties post-Damseaux”, [2009] Tax Journal, 14 September 2009, 9